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Re: 700 cancer cases caused by X-rays...Montclair NJ info...
Bill, the outcome was the removal of the vast majority of Ra-226
contaminated soils from over 175 properties (along with a small component Th-232
probably used when the facilty switched to Mesothorium in the belief that it
would be less hazardous) . The material involved was actually a process sand
that was freely dumped after Radium refinement from material that lacked
Radium's parental precursors ( only in one small area was Rn found in equilibrium
with its U parent) .The actual disputes as I understood them, did not involve
local landfills, but waste transportation and its' acceptence by another state.
Nobody wanted New Jersey's contaminated garbage nor would they allow it to
pass through their backyard (the anti's had a field day with this). This
neccessitated the current USEPA involvement as the NJDEP and the state of NJ did not
have the political horsepower to get the soil moving. The various horror
stories many may have heard date from that time when the NJDEP began remediation
with out securing the guarantees for disposal (eg homeowners out of their homes
for years, placarded barrels piled ten high, techs surveying rocks for free
release etc...). As for the book, it is well researched dry read of which I keep
a copy on my desk.
John, your conclusions are incorrect. The spectroscopic analysis of the
soils from the Montclair Superfund Project irrefutably contradict your
conclusions. It is pointless to go over that any further. In several instances, the
DOE's 4' soil barrier method was tried and abandoned as it was found to have
only temporarily reduced Rn-222 gas entry into the residences - over time the
levels returned as pathways were formed in response to the negative pressure
environment of a basement ( sealing is a poor method of mitigation and in this
instance, a very expensive one). Additionally, I cannot imagine short lived
RDP's as a "source of contamination".
As for the action levels stated in the Record Of Decision (ROD) when the
EPA assumed responsibiltiy for the project, they were the good ol' tried and
true 5 and 15's (pCi/g) OR interior Rn greater than 4 pCi/l. The vast
majority of remedial actions involved violations of the former criterion with the
latter being the recipients of a sub-slab mitigation system ( which was quite
effective at 20 pCi/l and certainly not $20,000). At no point was soil removed
solely to lower Rn-222 levels, except for the few soil barrier method test
homes (which as discussed earlier, proved largely fruitless). It should be stated
that very few homes exhibited elevated interior Rn levels to begin with, and
of those, all but 1 or 2 sat upon significant deposits of the waste stream
with activities in the 20 500 pCi/g range (Ra-226). The inclusion of the Rn
component in the ROD at all was, as I suspect, a way of trying to put a friendlier
face on the project. It always was a misnomer to call it a Radon remediation,
but that is what it is generally referred to as by the locals. Rn was a
problem that other homeowners elsewhere faced and it was after all "natural" ( one
didn't need to live on a superfund site to have it). You could feel the
increased level of fear in someone if the term was radioactive Radium as opposed to
Radon. People already had preconceived notions about Radon and would
generally not seem as interested in continued scientific discussions concerning nature
of their contamination as they felt it a somewhat known commodity. This also
had the nice fit with the rest of the USEPA's new initiative on Rn at that
time.
Now finally, to the 4 pCi/l threshold I hear so much about on the list.
This number as I understand it, like a lot of other regulatory numbers, relates
only to ALARA ( reasonable is subjective by definition). The EPA has discussed
reducing that level to 2 pCi/l - not because they believe that is the level
at which it is now safe - but because they believe the vast majority of homes
test in at significantly below this level, because they believe it is a
number that can be readily detected, and because they believe it is a level which
can be obtained without obtuse difficulty. There is no apparent epidemiological
basis upon which these levels rest. The EPA subscribes to LNT, and as long as
they do, they will continue to want all exposures reduced to as close to zero
as possible. I personally doubt the efficacy of the extrapolations upon which
LNT is based, nor do I have blind faith in regulatory simplifications
inherent in dose assessment, but I cannot as yet, find demonstrable proof to refute
them.
David Lawrence
Eberline Services
Montclair, NJ
These opinions are mine and definitely NOT THOSE OF MY EMPLOYER